We have established a whistleblowing scheme. We encourage you to read this before reporting your suspicion or concern via the scheme.
Who can use the whistleblowing scheme?
You can use the whistleblowing scheme if you are a current or former employee of DS Gruppen (‘whistleblowers’).
What can you report?
You can use our whistleblowing scheme if you have knowledge or reasonable suspicion of serious breaches of the law and other serious matters, as well as breaches of EU law as defined in the Directive of the European Parliament and of the Council on the protection of persons who report breaches of Union law. This may include, for example, the following:
- Criminal offences, e.g., fraud, embezzlement, misuse of assets, forgery of documents, accounting manipulation, bribery, corruption, money laundering, and terrorist financing
- Breaches of competition and procurement rules
- Danger to the health and safety of individuals, including serious or repeated breaches of workplace safety
- Significant breaches of environmental rules and pollution of the environment
- Breach of confidentiality
- Breaches of the protection of privacy and personal data
- Serious breaches of internal guidelines and rules within DS Gruppen (e.g., the individual companies’ staff handbooks and guidelines)
- Discrimination, severe bullying, severe harassment, physical violence, threats, and sexual misconduct
The above are only examples. If you are in doubt about whether your report falls within the scope of the whistleblowing scheme, we encourage you to use our whistleblowing scheme. The report will then be assessed, and you will receive feedback on whether your report is covered by the scope of the whistleblowing scheme.
Matters such as cooperation difficulties, dissatisfaction with salary conditions, minor breaches of internal guidelines regarding sickness absence, smoking, alcohol, use of office supplies, etc., should not be reported through the whistleblowing scheme, but must be reported through our normal management structure, i.e., to your immediate manager.
Do not use the whistleblowing scheme to report events that pose an immediate threat to life or property. If you require emergency assistance, please contact the public emergency services. We encourage you to use our whistleblowing scheme if you have a concern or suspicion regarding serious matters. However, you can also choose to report your suspicion or concern to the external whistleblowing schemes established by the authorities.
PwC
Your report goes directly to an external third party (PwC Statsautoriseret Revisionspartnerselskab ‘PwC’). PwC is an independent audit, tax, and advisory firm that receives reports on behalf of DS Gruppen to ensure an independent channel for you, the reporter. Subsequently, your report is forwarded for processing at DS Gruppen.
PwC conducts an initial assessment of whether the report is covered by the whistleblowing scheme and engages in a dialogue with whistleblowers if further information is needed, or if the report gives rise to follow-up questions. PwC will then carry out an impartiality assessment to determine who can handle the report within DS Gruppen, ensuring that the report can be processed by an impartial and competent person within DS Gruppen, and is thus not forwarded to a person whom the report concerns directly or indirectly, or where there may be a risk of a conflict of interest.
DS Gruppen’s Group HR Business Partner
DS Gruppen’s Group HR Business Partner is responsible for the whistleblowing scheme throughout DS Gruppen. The Group HR Business Partner is considered particularly competent and independent in relation to this area and is responsible for ensuring careful follow-up on reports and assessing what measures need to be implemented on the basis of your report.
You can read more about our whistleblowing scheme in our whistleblowing policy
Download whistleblowing policy
You can see more about the distribution of roles and responsibilities in this process overview
Confidentiality and objectivity
Everyone who receives and follows up on reports is subject to a special duty of confidentiality. The investigation of reports is carried out with due regard for independence, confidentiality, data protection, and security.
DS Gruppen and PwC treat all information regarding the identity of the whistleblower and the individuals concerned as strictly confidential to the greatest possible extent.
Protection of whistleblowers
DS Gruppen does not permit any form of retaliation or harassment against whistleblowers. A whistleblower who, in good faith, reports a reasonable suspicion or concern via the whistleblowing scheme will not face retaliation or be subjected to negative consequences, including consequences of an employment law nature, even if the report should later prove to be unfounded.
If you make a report from your work computer, and while you are on our network, or via the link to the scheme above, you should be aware that this will be recorded as part of the general logging of user activities on our network.
Alternatively, you can use our QR code to make the report via your phone or tablet. Please note that you must not be connected to the Wi-Fi network when making your report:
